Our bank is not required to do HMDA reporting for Year 2021 because the amount of loans we originated did not meet the threshold. However, if a customer asks us to see a copy of the HMDA report, what do we provide?

Are you talking about if they ask to see your 2021 reports? I would think you would just tell them that you are not a 2021 HMDA reporter due to your volumes, so you have no reports to provide to the public.

Also you are no longer required to provide the public a copy of your modified LAR. You are only required to provide them a notice that tells them they can obtain the information through the CFPB.

(c) Modified loan/application register. (1) A financial institution shall make available to the public upon request at its home office, and each branch office physically located in each MSA and each MD, a written notice that clearly conveys that the institution's loan/application register, as modified by the Bureau to protect applicant and borrower privacy, may be obtained on the Bureau's Web site at www.consumerfinance.gov/hmda.

And from 228.43 in the CRA

(2) Banks required to report Home Mortgage Disclosure Act (HMDA) data. A bank required to report home mortgage loan data pursuant part 1003 of this title shall include in its public file a written notice that the institution's HMDA Disclosure Statement may be obtained on the Consumer Financial Protection Bureau's (Bureau's) Web site at www.consumerfinance.gov/hmda. In addition, a bank that elected to have the Board consider the mortgage lending of an affiliate shall include in its public file the name of the affiliate and a written notice that the affiliate's HMDA Disclosure Statement may be obtained at the Bureau's Web site. The bank shall place the written notice(s) in the public file within three business days after receiving notification from the Federal Financial Institutions Examination Council of the availability of the disclosure statement(s).

Now with that said you are free to download the information from the CFPB Web site for the person requesting the information but the regulation no longer mandates the FI is responsible for providing the information to the public.